Modern Slavery Policy

1. What is the purpose of this policy?

We are committed to conducting our business ethically, including by eliminating risks of modern slavery practices in our business and supply chain. By implementing this policy, we aim to uphold our commitment to ethical practices and ensure that we and our suppliers comply with relevant laws and regulations, including the Modern Slavery Act 2018 (Cth).

2. Who does this policy apply to?

This policy applies to everyone involved in our business, including employees, directors, officers, labour hire staff, contractors, agency workers, suppliers, consultants, and other representatives of our business or of any business in our supply chain.

We expect all who have, or seek to have, a business relationship with us to familiarise themselves with this policy and to act in a way that is consistent with our values. We will only do business with organisations who fully comply with this policy, or those who are taking verifiable steps towards compliance.

While this policy is not part of any contract you may have with us, if you are involved in our business, we expect you to comply with it.

If you do not comply with this policy, we may end our relationship/engagement with you. If you are an employee, you may be subject to disciplinary measures including termination of employment.

3. What is modern slavery?

Modern slavery is the term used to describe exploitative practices that violate human rights.

It describes situations where someone in a position of power uses coercion, threats or deception to exploit an individual or undermine an individual’s freedom. Modern slavery involves serious exploitation, rather than sub-standard working conditions or the underpayment of workers (although this may be unlawful for other reasons).

Modern slavery can take many forms, including:

1. slavery — owning a person, trading in slaves or financing slave trading (eg human trafficking);

2. servitude — obligation to provide services imposed by coercion, threat or deception;

3. forced labour — work and service that is not voluntarily performed and obtained from an individual under coercion, threat or deception;

4. human trafficking — arranging or facilitating travel of an individual for exploitation;

5. forced marriage — a marriage without free and full consent (eg, due to lack of understanding or duress/coercion);

6. debt bondage — a person works to pay off a large debt, for an unlimited time or where the value of the work is not applied to the debt;

7. deceptive recruiting — a recruiter charges a fee for the job offer, confiscates identity documents, deceives a person about personal freedom or their ability to leave the job; and

8. child labour — exploiting children, depriving them of education, making them work in unsafe working environments.

4. Why do we want to limit risks of modern slavery practices?

Limiting modern slavery practices makes good business sense, as it protects our workers and our reputation. It also supports us in assessing and addressing modern slavery risks as required by modern slavery legislation, and it enhances stakeholder trust and confidence in our operations.

By actively working to prevent modern slavery, we contribute to the global effort to eradicate these practices and promote human rights.

5. What are our responsibilities?

We will endeavour to:

1. prepare a modern slavery statement in accordance with any requirement of Australian law;

2. identify and address modern slavery risks in our business and supply chain; and

3. take steps to raise awareness of modern slavery risks, including by having this policy.

6. What are your responsibilities?

You must take all reasonable steps to help us ensure our business and supply chain is free of modern slavery practices.

Whatever your business relationship with us, we ask that you pay close attention to your supply chain, particularly if you procure goods or services from businesses in jurisdictions without adequate safeguards.

Some areas of business are likely to have more exposure than others, including procurement and sourcing, human resources, finance, risk, sustainability, projects, legal and leadership.

Examples of specific responsibilities include:

1. participating in all training, including in this policy;

2. leading by example by making appropriate checks on all workers, recruitment agencies, suppliers, etc to ensure we know who is working for us;

3. remaining alert to indicators of slavery and worker exploitation;

4. using only approved contracts which include modern slavery clauses;

5. reporting any concerns or incidents of modern slavery to the designated compliance officer or through the appropriate reporting channels; and

6. following our instructions regarding modern slavery.

If you reasonably suspect that modern slavery may be occurring within our business or supply chain, we ask you to report it to us immediately.

7. How do I report slavery concerns?

Your awareness and actions may stop someone from being exploited or abused. By remaining alert and reporting your suspicions to us appropriately, you play a crucial role in combating modern slavery.

If you are or become aware of modern slavery practices, please discuss your concerns with us immediately, so that we may evaluate the situation, decide a course of action and provide any further advice.

8. Who is responsible for this policy?

Our directors are responsible for this policy and will review reports of material slavery concerns.

The policy may be amended, replaced or removed from time to time.